The doctrine of priest–penitent privilege does not apply in the UK. Before the Reformation, England was a Roman Catholic country and the Seal of the Confessional had great authority in the English courts. However, the Reformation was followed by a period of, often fierce, persecution of Catholics. Reach of canon law In the Codex Juris Ecclesiastici Anglicani (London, 1761) by Edmund Gibson, chaplain to the Archbishop of Canterbury and afterwards Bishop of London, is found a compilation of the various canons and constitutions which had been made for the Church in England at different times. In his introduction to that work, in which he cites the Act Concerning Peter's Pence and Dispensations which also deals with the exercise of papal jurisdiction in England, the author, in touching upon canon law, says as follows: He goes on to say that before the Reformation, their not being repugnant to the laws of the land was the condition of these laws being received here. But he also cites commentaries of John de Athon on certain constitutions of Otho and Othobon, which the commentator says were not received here. Gibson cites a constitution of Simon Sudbury, Archbishop of Canterbury (1378), ordering confessions to be heard three times a year, and that whoever would not confess at least once a year should be prevented from entering a church while living and should not receive Christian burial when dead. This order was to be published frequently in the churches. That the particular decree as to the secrecy of the seal of confession was locally re-enacted by English councils and synods has already been shown. Its importance, whether as enacted by the Lateran Councils or re-enacted by the English councils, seems to have been only confirmatory of something already well established in the Church or, at most, as definitely declaring the punishment for the violation of the secrecy. That the decree was allowed and accepted by the civil courts of England can only be a matter for deduction. There is no direct proof of it, as there is, for instance, in the cases of these two other decrees, which are cited only as some evidence of the probability of the acceptance of this particular decree. Before enumerating other and chief grounds of this probability it is well to remember that if the law of the secrecy of confession was already well established in the Church it would